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CSUM 24/03
31 May 2024
19 Apr 2024
Appeal Status
No right of appeal

TRA finds Notice of Claim defective so proceedings a nullity, alternatively Challenge deemed withdrawn

The Taxation Review Authority (TRA) has no jurisdiction to hear a Challenge Proceeding regarding the imposition of use of money interest.

The Disputants failed to file a valid Notice of Claim concerning a second issue which had the potential to be within the TRA’s jurisdiction. Accordingly, the Challenge Proceedings were defective (a nullity) with no evident path to rectification.

The Disputants failed to attend a mandatory directions hearing. There was no good reason for this and there were no exceptional circumstances. The result being the proceedings are at an end.

Tax Information Bulletin - Vol 36 No 5, June 2024

TRA 007/22 [2024] NZTRA 003

Tax Administration Act 1994, s120I
Taxation Review Authorities Regulations 1998, regs 7, 30(2) and 32

TRA 007/22 [2024] NZTRA 003